AQ_F_1600155_20210702_ST_RvwMemo

DIVISION OF AIR QUALITY
Technical Services Section
July 2, 2021
MEMORANDUM
To: Brad Newland, P.E., Wilmington Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB) 7e
Subject: Collins Tree Service Pit
Newport, Carteret County, North Carolina
Facility ID 1600155, Air Permit No. 10655000
Initial Visible Emissions Testing of NSPS Subpart EEEE Trench Burner ID No. ACI
Performed on December 11, 2020 by Collins Tree Service Pit
Tracking No. 2020-300ST
A report of the subject testing has been reviewed. The Method 9 visible emissions testing
results demonstrate compliance with the applicable emissions standards. The source tested is
a portable air curtain incinerator (ACI) listed in the permit as Air Burners T-300 Trench Burner
(10 tons per hour firing capacity) that commenced construction after December 9, 2004. The
Method 9 opacity results are tabulated below.
The emissions standards that apply are:
• 15A NCAC 2D .1904 Air Curtain Incinerators (as Readopted Eff. September 1, 2019)
o Limits opacity to <_ 35% opacity (as determined by the average of 3 1-hour blocks
consisting of 10 6-minute average opacity values) during startup of the incinerator.
Incinerator startup is defined as the first 30 minutes of operation.
o Limits opacity to <_ 10% opacity (as determined by the average of 3 1-hour blocks
consisting of 10 6-minute average opacity values) at all times, other than during
startup or during malfunctions.
• 40 CFR Part 60 Subpart EEEE Standards of Performance for Other Solid Waste
Incineration Units for Which Construction is Commenced After December 9, 2004, or for
Which Modification or Reconstruction is Commenced on or After June 16, 2006
o Limits opacity to <_ 10% opacity (6-minute average) at all times, except during the
startup period that is within the first 30 minutes of operation or during malfunctions.
o Limits opacity during the startup period to <_ 35% opacity (6-minute average) during
startup period that is within the first 30 minutes of operation.
Table 1: Initial Test for EPA Method 9 Opacity Emission: (Test Readings as Observed by Kevin Wright)
Emission
Source Emission Source Test Test Results Limit Emissions
ID Description Date Average Opacity Opacity Standard Compliance
Air Burner T-300 Trench Burner 6.13%(3-hour Test Average) <_10% 15A NCAC 2D .1904 Indicated
ACI (10 tons per hour firing capacity) 12-11-20 8.75%(Highest 6-minute Average) <_10% 60 Subpart EEEE Indicated
The visible emissions observation forms indicate the test period operating mode was 90% of
maximum normal. Representative testing is considered to be greater than approximately 90%
of maximum normal. Therefore this test was accepted.
Compliance was indicated for visible emissions from Air Burners T-300 Trench Burner ACI.
Note permit condition 2.1.A.2.e require subsequent annual opacity testing no more than
12 calendar months following the date of the previous test. If there are any questions
concerning this matter, please contact me at [phone] or gregg.oneal(a)ncdenr.gov.
cc: Central Files, Carteret County
IBEAM Documents— 1600155